Health Advisory Levels lowered for Perfluoroalkyl Substances; Regulation on the Horizon – What to expect

By Robert Hollander, P.E.

What are PFAS?

Perfluoroalkyl Substances (PFAS) are a group of chemicals used in the manufacture of many industrial and consumer products, such as fire-fighting foams, fabric treatments, and coatings on non-stick cookware. The high stability of these chemicals make them persistent in the environment, and have therefore been described as “forever chemicals”. PFAS are being released into the environment from their use, manufacture, and unplanned discharges. They are being found in water resources, land, and in the air.

Why is there a concern regarding PFAS?

Due to their persistence in the environment, PFAS may accumulate in the bodies of humans and other living organisms. Based on current data, health effects that may be attributed to PFAS include reproductive, developmental, increased risk of certain cancers, immune system impacts, and hormonal impacts. The effects are being seen from very low levels of these chemicals. Research is underway and ongoing.

What actions are being taken to address PFAS contamination?

Federal Government

Due to its accumulation and persistence in the environment EPA has been tasked with addressing PFAS contamination in all environmental media. As a result, EPA published their PFAS Action Plan in February 2019, followed by the PFAS Roadmap (Roadmap) on October 18, 2021. The Roadmap outlines actions and establishes a timetable for addressing PFAS contamination in water (i.e. surface water, groundwater, and drinking water), waste materials, and air. Below see some key actions that EPA has taken or plans to take to address PFAS in drinking water and wastewater.

  • On June 15, 2022, EPA announced updated Health Advisory Levels (HALs) for perfluorooctanoic acid (PFOA) and perfluorooctanesulfonate (PFOS)
    • PFOA – 0.004 parts per trillion (ppt)
    • PFOS – 0.02 ppt
    • The levels of PFOA and PFOS combined had previously been set at 70 ppt
  • Also, on June 15, 2022, EPA announced Public Health Advisories (HAs) for Publish health advisories for hexafluoropropylene oxide (HFPO) dimer acid and its ammonium salt (collectively know as GenX chemicals) and for perfluorobutane sulfonic acid and its related compound potassium perfluorobutane sulfonate (PFBS)
    • GenX – 10 ppt
    • PFBS – 2,000 ppt
  • To address the new HALs and HAs, EPA will make available an initial $1 billion of Bipartisan Infrastructure Law Funding, especially for communities facing disproportionate impacts, which will compliment Safe Drinking Water and Clean Water State Revolving Loan funding.
  • Nationwide monitoring of PFAS in drinking water
    • Unregulated Contaminants Monitoring Rule 5 (UCMR 5)
      • Proposed Rule issued March 2021 – 29 PFAS
      • Final Rule December 27, 2021
      • Public water systems with populations >3,300 and select group of 800 water systems <3,300 to collect samples January 2023-December 2025
    • Establish a National Primary Drinking Water Regulation (NPDWR) or standards for PFOA and PFOS
      • Proposed Rule Expected Fall 2022
      • Final Rule Expected Fall 2023
      • Recently revised HALs for PFOA and PFOS suggest that final Maximum Contaminant Levels (MCLs) could be single digit or teens of parts per trillion
    • Effluent Limitations Guidelines (ELGs) to restrict industrial discharges of PFAS to waterways and wastewater systems
      • Expected 2022 and ongoing
    • Use NPDES permitting to reduce PFAS discharges to waterways
      • Expected Winter 2022
      • Initially monitoring requirements for PFAS
      • Guidance to state permitting authorities
    • Publish final recommended ambient water quality criteria for PFAS (the criteria are used by states and tribes to establish surface water quality standards which can be included in NPDES Permits)
      • Aquatic life criteria expected Winter 2022
      • Human health criteria expected Fall 2024



Massachusetts, Michigan, New Hampshire, New Jersey, New York, and Vermont have adopted regulations and drinking water standards for some PFAS compounds. In addition, California, Connecticut, Illinois, Minnesota, and North Carolina have adopted a variety of response levels, notification levels, and health advisory levels. In response to the published updated HALs for PFOA and PFOS and new HAs for GenX and PFBS, Arizona will provide information to public water systems on sampling, treatment, and funding options. Public water systems are encouraged to contact their State primacy agencies to learn about their current requirements regarding PFAS.


Stay tuned for updates on these efforts and how they may impact you.



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